PR. COMMISSIONER OF INCOME TAX-10, NEW DELHI vs. JANAK RAJ GUPTA AND COMPANY

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ITA/248/2026HC DelhiDLHC01132224202425 March 2026Bench: HON'BLE MR. JUSTICE VINOD KUMAR,HON'BLE MR. JUSTICE DINESH MEHTA2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the appeals filed by the Principal Commissioner of Income Tax. The decision was based on the submission made by the Revenue's counsel that the tax effect in these appeals was below the monetary limits stipulated in CBDT Circular No. 5/2024 and Circular No. 9/2024. The Court accepted this submission and proceeded to dismiss the appeals. No specific findings were made on the merits of the ITAT orders. The ratio decidendi is that appeals filed by the Revenue, where the tax effect is below the prescribed monetary limits as per CBDT circulars, are liable to be dismissed. The operative direction was the dismissal of the appeals.

What were the facts?

The appeals were filed by the Principal Commissioner of Income Tax against the respondent, Janak Raj Gupta (in ITA 247/2026) and Janak Raj Gupta and Company (in ITA 248/2026). The appeals challenged orders passed by the Income Tax Appellate Tribunal (ITAT). The learned counsel for the appellant submitted that the tax effect in these appeals falls below the limits prescribed in CBDT Circular No. 5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. The specific assessment years and the amounts in dispute were not explicitly stated in the provided text. The procedural history leading to the ITAT orders was not detailed.

What were the issues?

1. Whether the appeals filed by the Revenue are maintainable in light of the tax effect being below the monetary limits prescribed by the CBDT Circulars? Assessee's Contention: The judgment does not record any specific contentions from the assessee's side. The respondent's counsel did not appear. Revenue's Contention: The learned counsel for the appellant (Revenue) submitted that the tax effect in the instant appeals falls below the limits prescribed in CBDT Circular No. 5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. This submission implies that the Revenue itself is seeking dismissal of the appeals on this ground.

AI-generated summary — verify with the full judgment below

$~41 & 42 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 247/2026 & CM APPL. 18768/2026

PR. COMMISSIONER OF INCOME TAX .....Appellant Through: Mr.Gaurav Gupta, SSC with Mr.Shivendra Singh & Mr. Yojit Pareek, JSCs and Mr. Surya Jindal, Adv.

versus

JANAK RAJ GUPTA

.....Respondent Through: Counsel (appearance not received)

+ ITA 248/2026 & CM APPL. 18776/2026

PR. COMMISSIONER OF INCOME TAX-10, NEW DELHI

.....Appellant Through: Mr.Gaurav Gupta, SSC with Mr.Shivendra Singh & Mr. Yojit Pareek, JSCs and Mr. Surya Jindal, Adv.

versus

JANAK RAJ GUPTA AND COMPANY

.....Respondent Through: Counsel (appearance not received)

CORAM:

HON'BLE MR. JUSTICE DINESH MEHTA

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

25.03.2026 1. Learned counsel for appellant submitted that the tax effect in the instant appeals fall below the limits prescribed in CBDT Circular No.5/2024 dated 15.03.2024 read with Circular No. 9/2024 dated 17.09.2024. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/03/2026 at 15:56:53

2.

In view of the aforesaid, the appeals are dismissed.

DINESH MEHTA, J

VINOD KUMAR, J MARCH 25, 2026 kk

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/03/2026 at 15:56:53

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